Reginald E. Daniels, Adm'r v. John K. Evans
107 N.H. 407 (1966)
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Rule of Law:
A minor who engages in an inherently dangerous activity normally undertaken by adults, such as operating a motor vehicle, is held to the same standard of care as a reasonable adult.
Facts:
- Robert E. Daniels, who was 19 years old, was operating a motorcycle.
- Daniels was involved in a motor vehicle accident which resulted in his death.
Procedural Posture:
- A lawsuit was filed in a trial court on behalf of the estate of the deceased, Robert E. Daniels.
- At trial, the court instructed the jury that Daniels' conduct should be judged by the standard of care of an average child of his age, experience, and development.
- The defendant objected to this jury instruction.
- Following the trial, the defendant appealed the trial court's instruction to the Supreme Court of New Hampshire.
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Issue:
Does the special standard of care for minors, which considers their age, experience, and maturity, apply when a minor is engaged in an inherently adult and dangerous activity such as operating a motor vehicle?
Opinions:
Majority - Lampron, J.
No. A minor operating a motor vehicle must be judged by the same standard of care as an adult. The court reasoned that the traditional, lenient standard for minors is appropriate only for activities suitable to their age and experience, such as playing or riding a bicycle. However, when a minor engages in an adult activity that is potentially dangerous to the public, such as operating a motor vehicle, public policy requires that they be held to an adult standard of care. The court noted that other drivers on the road have no way of knowing a driver is a minor and thus cannot guard against youthful imprudence. Furthermore, the legislature has indicated its intent to treat minor drivers as adults by making traffic laws applicable to 'any person' and by removing most motor vehicle violations for those 16 and over from juvenile court jurisdiction. Therefore, applying a lower standard of care to minor drivers is unrealistic and inimical to public safety.
Analysis:
This decision marks a significant departure from the traditional common law rule that a minor's conduct is judged based on a standard of care of a reasonably prudent person of the same age, intelligence, and experience. By creating an 'adult activity' exception, particularly for operating motor vehicles, the court aligned New Hampshire with a modern trend in tort law. This precedent effectively holds teenagers to the same level of responsibility as adults when they undertake activities that can pose a grave danger to the public, significantly impacting personal injury cases involving minor drivers. The ruling clarifies that the right to engage in such activities comes with the assumption of adult-level responsibilities.
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